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Recent Projects

  • Petition for Rulemaking for the Federal Trade Commission to Ban Drip Pricing

    Drip pricing is a strategy used by some sellers to lure in consumers by advertising deceptively low prices, only to reveal hidden mandatory fees after the consumer is on the verge of completing a transaction. We submitted a petition to the Federal Trade Commission formally calling for a new rule banning the use of drip pricing.

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  • Comments to EPA on Withdrawal of California Preemption Waiver

    The Environmental Protection Agency is reconsidering its withdrawal of a waiver of preemption for California’s zero emission vehicle mandate and greenhouse gas emission standards. We submitted comments supporting the rescission of the waiver withdrawal.

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  • Comments to EPA on Proposed Phasedown of HFCs

    In the Environmental Protection Agency's phasedown of HFCs under the new HFC legislation, the agency calculates a new set of social cost values for HFCs directly, using the same approach as for the social cost of methane. We submitted comments supporting EPA's methodology and encourage EPA to incorporate the SC-HFC into the IWG process going forward. 

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  • Comments to DOE on Energy Conservation Standards for Clothes Dryers

    The Department of Energy's preliminary technical support document  indicates that DOE will use the domestic-only, interim social cost of carbon dioxide, methane, and nitrous oxide values developed under the now-repealed Executive Order 13,783. We submitted comments explaining that DOE should follow the reconvened Interagency Working Group’s February 2021 recommendations.

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  • Comments to OMB on Advancing Equity and Supporting Underserved Communities

    In his Presidential Memorandum titled Modernizing Regulatory Review, President Biden called on OMB to identify measures to promote racial justice in the regulatory review process. We submitted comments outlining procedures and methodologies that OMB could apply to account for equity in the regulatory review process, with a focus on environmental injustice.

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  • Climate and Power System Reliability in the Aftermath of the Texas Blackouts Cover

    Climate and Power System Reliability in the Aftermath of the Texas Blackouts

    The February 2021 blackout in Texas underscored the importance of reliable and resilient power systems. This article discusses the roles of regulators, markets, fuel and generation supply chains, and interdependent infrastructures, and finds that they need to be reconsidered and redefined to successfully meet the future challenges of increased electrification and severe weather

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  • Comments to DOE on Energy Conservation Standards for Single Package Vertical Units

    The Department of Energy (DOE) asked for input on conducting its national impact analysis, including on market failures, its emissions analysis, and monetization of benefits of emissions reductions. We submitted comments suggesting that DOE continue to monetize the full climate benefits of emissions reductions using the best available estimates of the social cost of greenhouse gases. 

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  • Comments to the Interagency Working Group on the Social Cost of Greenhouse Gases

    As part of its process for revising the social cost of greenhouse gas values, the Interagency Working Group requested public input. We published and submitted five original reports on key issues, as well as a comment letter that summarizes the reports and offers several additional points for the Working Group’s consideration.

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  • Playing with Fire Cover

    Playing with Fire

    Responding to Criticism of the Social Cost of Greenhouse Gases

    Federal agencies will need to offer considered and detailed responses to objections raised in the notice-and-comment processes for individual regulations or administrative actions that apply the Working Group’s social cost valuations. Given its expertise, the Working Group should consider providing such responses now, so that agencies can then incorporate them into future actions. This report offers a blueprint for those responses.

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  • Expert Elicitation and the Social Cost of Greenhouse Gases Cover

    Expert Elicitation and the Social Cost of Greenhouse Gases

    The Interagency Working Group on the Social Cost of Greenhouse Gases can use the findings from expert elicitations to improve the U.S. federal government’s social cost of greenhouse gas estimates, which are used in regulatory cost-benefit analysis and other policy contexts. Our report highlights several component updates, incorporating data from expert elicitations, that the Working Group should consider during its current update of the social cost of greenhouse gas estimates.

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